Enforcement report 2018/19

Safer Gambling - Healthcheck

Good practice

You should be asking yourself the following key questions with regards to customer interaction and identifying problem gamblers:

• Do you have policies and procedures in place to identify customers who may be experiencing or at risk of developing problems with their gambling? Have you allocated sufficient resources to be able to interact with customers early and effectively when you have concerns?
• Are you curious about your customers? Do you monitor customer activity?
• Do you record interactions and use this information to aid your decision making about customers?
• Do you track customers across your different platforms and do enough to spot multiple customer accounts?
• Do you have systems in place to identify potential problem gamblers? Do these include appropriate and realistic trigger points for when the usual pattern of gambling becomes unusual (these should not just be financial)? How do you protect new or unknown customers (where a pattern of play cannot yet be established)?
• Will your processes keep pace with increased demand? Will your growth or any merger affect your ability to monitor customers?
• How are you evaluating these measures and procedures to ensure they are effectiveand how do you plan to make improvements over time?
• Are your staff sufficiently trained to spot gamblers who might be experiencing harmand know how to report concerns? Are there clear procedures once a concern has been raised? Are there processes in place for weekends and late nights?
• Where concerns arise, are you able to intervene early and engage with a customer?
• Do your customer interaction policies and procedures also cover VIP customers?
• Are you alert to the particular risk these customers bring? Are commercial considerations overriding customer protections?
• Have you considered how you will meet the revised LCCP requirements for customer interaction? Have you reviewed your own processes against the guidance, and considered changes you need to make to meet the requirements from October 2019?

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